|Subject:||Request Relating to Information Pertaining to Terrorist Attacks|
|Date of Memorandum:||10/17/2001|
|Expiration Date:|| |
|Signed By:||Reyna, Michael|
|FCA Contact Person:||Cohen, Victor|
|List of Attachments:|
Farm Credit Administration 1501 Farm Credit Drive
McLean, Virginia 22102-5090
October 17, 2001
To: The Chairman, Board of Directors
Chief Executive Officer
Each Farm Credit System Institution
From: Michael M. Reyna
Chairman and Chief Executive Officer
Subject: Request Relating to Information Pertaining to the Terrorist Attacks
In the wake of the recent terrorist attacks on this country, the financial community has been asked to cooperate with law enforcement authorities in their ongoing investigations. The Farm Credit Administration, along with other financial institution regulators, has encouraged financial institutions to work with law enforcement and to review their records to determine if any transactions or relationships exist or existed with individuals or entities that have been identified by the FBI and other law enforcement authorities. In that regard, we have worked with law enforcement on a mechanism that will assure the expeditious distribution of a unified list of individuals and entities to a broad range of financial institutions. This list will be referred to as the Control List. Because the Control List contains confidential information, we ask that you disseminate the information within your institution on a need-to-know basis. Under no circumstances should the Control List or the information contained in it be disseminated outside your institution.
Law enforcement will provide the Control List to the Farm Credit Administration. We will, in turn, send your institution a copy of the Control List through e-mail. We will also send electronic updates to the list on a regular basis. We need your immediate help in starting this process. We request that you designate a senior-level individual within your institution who appreciates the sensitive nature of the investigation and will exercise appropriate discretion to be the point person for all communications relating to the Control List. Please provide this person’s name, title, telephone number and, most importantly, e-mail address by Friday, October 19, 2001. Please send this information to the following e-mail address: email@example.com.
Once this information is received, the Control List will be distributed, and your institution will be asked to check its records to determine whether any of the individuals or entities on the Control List have or have had any transactions or relationships with your institution in the United States or elsewhere.
If your institution identifies any transaction or relationship with any of the individuals or entities, you are requested to promptly send an e-mail message to firstname.lastname@example.org indicating only that you have a positive response. This information will be transmitted to law enforcement authorities, who can obtain a subpoena to be served on your institution for relevant customer records.
You should note that the Control List does not supersede your institution's obligations with respect to property, transactions, and activities of terrorists identified by the Office of Foreign Assets Control (OFAC). You should regularly check the OFAC Web site at http://www.ustreas.gov/ofac/index.html to receive the most current OFAC information. You should contact OFAC at (800) 540-6333 when you identify a matter subject to the OFAC list. This obligation is separate and apart from the Control List and the contact process described in this memorandum.
In addition, you are reminded to report any suspected violation related to any of the names on the Control List by filing a Referral Form in accordance with the Farm Credit Administration rules for referral of suspected criminal violations at 12 CFR § 617.2. If you have any questions, please call Victor Cohen, Associate General Counsel, at (703) 883-4020 or write to him on the Internet at the e-mail address email@example.com.
We thank you for all of your efforts in this most important endeavor.